Case 9:08-cv-80736-KAM Document 362-41 Entered on FLSD Docket 02/10/2016 Page 2 of 2 From: Sent: To: Cc: Subject: Importance: Dear Jack: .(USAFLS) (USAFLS) Nliz•- idW. July Of, 2008 10:53 AM rger E N. (FBI); e rey psein High Jason R (FBI); Atkinson, Karen (USAFLS) Special Agent reminded me that I failed to include one of our identified victims. She is still a minor, and her initials are Please let me know when you are available, and I will provide you with the revised list. I would like to receive the signed notification by tomorrow so that I can begin distributing them to the victims. Thank you. A. Marie Villafafla Assisi ant 696 08-80736-CV-MARRA RFP WPB-001854 EFTA00185052

Case 9:08-cv-80736-KAM Document 362-42 Entered on FLSD Docket 02/10/2016 Page 1 of 10 EXHIBIT 112 EFTA00185053

Case 9:08-cv-80736-KAM "foment 362-42 Entered on FLSD irket 02/10/2016 Page 2 of 10 FILED by DJ D.C. nacmotaie JULY 7, 2008 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA 08-80736-Civ-MARRA/JOHNSON CASE NO.: IN RE: JANE DOE, Petitioner. STEVEN M. LARIMORE CLERK U.S. DIST. CT. S•O. OF FLA. • MIAMI s.? cry enc y VICTIM'S PETITION FOR ENFORCEMENT OF CRIME VICTIM'S RIGHTS ACT, 18 U.S.C. SECTION 3771 COMES NOW the Petitioner, JANE DOE (hereinafter "Petitioner"), by and through her undersigned attorneys, pursuant to the Crime Victim's Rights Act, 18 U.S.C. Section 3771 ("CVRA"), and files this Petition for Enforcement in the above styled action as follows: 1. Petitioner, an adult, as a minor child was a victim of federal crimes committed by JEFFREY EPSTEIN (hereinafter "Defendant"). These crimes included sex trafficking of children by fraud, in violation of 18 U.S.C. § 1591, use of a means of interstate commerce to entice a minor to commit prostitution, in violation of 18 U.S.C. § 2422, as well as wire fraud, in violation of 18 U.S.C. § 1343. The Defendant committed these crimes within the jurisdiction of the Southern District of Florida in Palm Beach County, Florida. 2. Upon information and belief, the Defendant is the subject of a federal criminal investigation conducted by the United States of America in the Southern District of Florida. The Defendant has recently been prosecuted and pleaded guilty, on June 30, 2008, in the Circuit Court for Palm Beach County to various similar state offenses including solicitation of minors for prostitution. 3. Upon information and belief, the Defendant is engaged in plea negotiations with the Office of the United States Attorney for the Southern District of Florida concerning federal of 10 EFTA00185054

Case 9:08-cv-80736-KAM cument 362-42 Entered on FLSD ket 02/10/2016 Page 3 of 10 crimes which he is alleged to have committed against minor children, including the Petitioner. Such negotiations may likely result in a disposition of the charges in the next several days. 4. Under the CVRA, before any charges are filed against the Defendant, the Petitioner has the rights (among others) to notice of her rights under the CVRA, to confer with the prosecutors, and to be treated with fairness. As soon as charges are filed, the Petitioner has the rights (among others) to timely notice of court proceedings, the right not to be excluded from such proceedings, the right to be heard at such public proceedings regarding conditions of release, any plea, and any sentence, the right to confer with the attorney for the government, the right to restitution, and the right to be treated with fairness and with respect for her dignity and privacy. 5. The Petitioner has been denied her rights in that she has received no consultation with the attorney for the government regarding the possible disposition of the charges, no notice of any public court proceedings, no information regarding her right to restitution, and no notice of rights under the CVRA, as required under law. 6. The Petitioner is in jeopardy of losing her rights, as described above, if the government is able to negotiate a plea or agreement with the Defendant without her participation and knowledge. WHEREFORE, for the reasons outlined above, the Petitioner respectfully requests this Court to grant her Petition, and to order the United States Attorney to comply with the provisions of the CVRA prior to and including any plea or other agreement with the Defendant and any attendant proceedings. 2 EFTA00185055

Case 9:08-cv-80736-KAM cument 362-42 Entered on ELSDicket 02/10/2016 Page 4 of 10 MEMORANDUM I. THE CRIME VICTIMS' RIGHTS ACT MAKES CRIME VICTIMS INDEPENDENT PARTICIPANTS THROUGHOUT THE CRIMINAL JUSTICE PROCESS. In October 2004, Congress passed and the President signed into law the Crime Victims' Rights Act, Pub. L. No. 108-405, 118 Stat. 2251 (codified at 18 U.S.C. § 3771). Because this appears to be the first case involving the Act to come before this Court, a bit of background may be in order. A. The CVRA Gives Crime Victims Rights to Participate in the Criminal Justice Process. Congress passed the CVRA "to give crime victims enforceable rights to participate in federal criminal proceedings." Opinion at 14. Congress was concerned that in the federal system crime victims were "treated as non-participants in a critical event in their lives. They were kept in the dark by prosecutors too busy to care enough ... and by a court system that simply did not have a place for them." 150 CoNG. REC. S4262 (Apr. 22, 2004) (statement of Sen. Feinstein). To remedy this problem, Congress gave victims "the simple right to know what is going on, to participate in the process where the information that victims and their families can provide may be material and relevant ... ." Id. The CVRA gives victims of federal crimes a series of rights, including the right to notice of court proceedings, to be heard at plea and sentencing hearings, and to reasonably "confer with the attorney for the Government in the case." 18 U.S.C. § 3771(a). Victims also have a "right of access to the terms of a plea agreement ... ." In re Interested Party 1, 530 F.Supp. 2d 136, 2008 WL 134233 at *7 (D.D.C. 2008). The CVRA also assures victims broadly that they will "be treated with fairness." 18 U.S.C. § 377I(a)(8). 3 EFTA00185056

Case 9:08-cv-80736-KAM cument 362-42 Entered on FLSD cket 02/10/2016 Page 5 of 10 Of course, these rights would be of little use to most crime victims unless they were told about them. To ensure that victims are notified of their rights, the CVRA directs employees of the Justice Department "and other departments and agencies of the United States engaged in the detection, investigation, or prosecution of crime" to use their "best efforts to see that crime victims are notified of ... the rights described [in the CVRA]." 18 U.S.C. § 3771(c)(1) (emphasis added).1 B. The CVRA Gives Victims Rights During the Investigation of a Crime. The CVRA gives victims rights during the investigation of a crime. The Fifth Circuit recently reached this conclusion, holding: The district court acknowledged that "[t]here are clearly rights under the CVRA that apply before any prosecution is underway." BP Prods., 2008 WL 501321 at *11. 2008 U.S. Dist. LEXIS 12893, at *36. Logically, this includes the CVRA's establishment of victims' "reasonable right to confer with the attorney for the Government." 18 U.S.C. ti 3771(a)(5). At least in the posture of this case (and we do not speculate on the applicability to other situations), the government should have fashioned a reasonable way to inform the victims of the likelihood of criminal charges and to ascertain the victims' views on the possible details of a plea bargain. In re Dean, 527 F.3d 391, 394 (5th Cir. 2008). The position that CVRA rights apply before charges have been filed is consistent with the Justice Department regulations under the CVRA, which explain that government officials "must advise a victim [about their rights under the CVRA] ... at the earliest opportunity at which it may be done without interfering with an investigation." A.G. GUIDELINES FOR VICTIM AND WITNESS I Further supporting this requirement is another statute, 42 U.S.C. § I0607(cX3), which directs government officials to provide victims with "the earliest possible notice of," among other things, "the filing of charges against a suspected offender." 4 EFTA00185057

Case 9:08-cv-80736-KAM cument 362-42 Entered on FLSD cket 02/10/2016 Page 6 of 10 ASSISTANCE 23 (May 2005). And the plain language of the CVRA undergirds this conclusion, as it applies not simply to prosecutors but to government agencies "engaged in the detection [and] investigation ... of crime ... ." 18 U.S.C. § 3771(c)(1). Indeed, if there were any doubt, the plain language of the CVRA extends victims' right to situations "in which no prosecution is underway." 18 U.S.C. § 3771(d)(3). II. PETITIONER IS A "VICTIM PROTECTED BY THE CVRA. Under the CVRA the crime victim is defined as "a person directly and proximately harmed as a result of the commission of a Federal offense ... ." 18 U.S.C. Section 3771(e). In particular, Defendant called Petitioner when she was a minor over a telephone (a means of interstate communication) requesting that she perform a massage in exchange for payment. As Defendant well knew, that request was fraudulent, as he not only intended to receive a massage, but also intended to have her perform sexual acts in exchange for a cash payment to Petitioner. Only when Petitioner arrived at a Defendant's mansion as directed by Defendant, did Defendant reveal his true purpose of obtaining sexual favors in exchange for payment. This conduct violated 18 U.S.C. § 2422, which forbids using a means of interstate commerce to knowingly "induce" or "entice" a minor "to engage in prostitution." In addition, this conduct was both a use of "fraud" to obtain a commercial sex act, in violation of 18 U.S.0 § 1591, and use of wire communications to perpetrate a "scheme and artifice to defraud," in violation of 18 U.S.C. § 1343. It appears obvious that Petitioner was "directly and proximately" harmed by these crimes, thereby making her a victim under the CVRA. It should be emphasized that the CVRA "was designed to be a `broad and encompassing' statutory victims' bill of rights." United States' 5 EFTA00185058

Case 9:08-cv-80736-KAM rent 362-42 Entered on FLSD cket 02/10/2016 Page 7 of 10 Degenhardt, 405 F.Supp.2d 1341, 1342 (D. Utah 2005) (quoting 150 Cong. Rec. S426I (daily ed. Apr. 22, 2004) (statement of Sen. Feinstein)). Congress intended the CVRA to dramatically rework the federal criminal justice system. In the course of construing the CVRA generously, the Ninth Circuit observed: "The criminal justice system has long functioned on the assumption that crime victims should behave like good Victorian children -- seen but not heard. The Crime Victims' Rights Act sought to change this by making victims independent participants in the criminal justice process." Kenna' U.S. Dist. Court for C.D. Cal., 435 F.3d 1011, 1013 (9th Cir. 2006). Accordingly, because the CVRA is remedial legislation, courts should interpret it "liberally to facilitate and accomplish its purposes and intent." Elliott Industries Ltd. Partnership'. BP America Production Co., 407 F.3d 1091, 1118 (10th Cir. 2005) (noting remedial legislation should be "interpreted liberally to facilitate and accomplish its purposes and intent"). The CVRA itself suggests this conclusion by requiring that courts must treat crime victims with "fairness." United States' Patkar, 2008 WL 233062 at *3 (D. Haw. 2008) (citing United States' Turner, 367 F.Supp.2d 319, 335 (E.D.N.Y. 2005)). Not only must the CVRA as a whole be interpreted liberally, but its definition of "crime victim" requires a generous construction. After reciting the direct-and-proximate-harm language at issue here, one of the Act's two co-sponsors -- Senator Kyl -- explained that "[t]his is an intentionally broad definition because all victims of crime deserve to have their rights protected ." 150 Cong. Rec. S10912 (Oct. 9, 2004) (emphasis added). The description of the victim definition as "intentionally broad" was in the course of floor colloquy with the other primary sponsor of the CVRA and therefore deserves significant weight. See Kenna, 435 F.3d at 1015-16 (discussing significance of CVRA sponsors= floor statements). 6 EFTA00185059

Case 9:08-cv-80736-KAM iicurrent 362-42 Entered on FLSD cket 02/10(2016 Page 8 of 10 The definition of "crime victims" must thus be construed broadly in favor of Petitioner. She obviously qualifies as a "victim" under the CVRA. III. PETITIONER IS ENTITLED TO NOTICE OF HER RIGHTS, AN OPPORTUNITY TO CONFER WITH THE PROSECUTORS AND TO BE TREATED WITH FAIRNESS. Because Petitioner is a "victim" under the CVRA, she has certain protected rights under the Act. Most important, the Act promises that she will have an opportunity to "confer with the attorney for the Government in the case." To date, Petitioner has not been given that right. This raises that very real possibility that the Government may negotiate and conclude a plea agreement with the Defendant without giving Petitioner her protected rights.2 Petitioner is entitled to have this conference with prosecutors before any final plea agreement is reached. The Fifth Circuit reached exactly this conclusion in a very recent case. In In re Dean, 527 F.3d 391 (5th Cir. 2008), the Government negotiated a plea agreement with the well-heeled corporate defendant without conferring with the victims. When the Government's failure was challenged in the Fifth Circuit, the Fifth Circuit concluded that the Government had indeed violated the CVRA. The Fifth Circuit observed: "In passing the [CVRA], Congress made the policy decision-which we are bound to enforce-that the victims have a right to inform the plea negotiation process by conferring with prosecutors before a plea agreement is reached." Id. at 394. This Court is obligated to protect the rights of Petitioner. The CVRA directs that "[i]n any court proceeding involving an offense against a crime victim, the court shall ensure that the 2 On information and belief, roughly the same crimes were committed against several other young females. These victims, too, are in danger of losing their right to confer under the CVRA. EFTA00185060

Case 9:08-cv-80736-KAM cument 362-42 Entered on FLSDaticket 02/10/2016 Page 9 of 10 crime victim is afforded the rights described in [the CVRA]." 18 U.S.C. § 3771(b)(1). The CVRA also confers on crime victims the right to "assert the rights described in [the CVRA]." 18 U.S.C. § 3771(d)(1). Therefore, this Court has its own independent obligation to intercede and ensure that the Government respects the rights of Petitioner under the CVRA. CONCLUSION The Petitioner requests the intervention of this Court to ensure that her rights are respected and accorded, as promised in the Crime Victims' Rights Act. DATED this 7th day of July, 2008. Respectfully Submitted, THE LAW OFFICE OF BRAD EDWARDS & ASSOCIATES, LLC Brad Edwards, Esquire Attorney for Petitioner Florida Bar #542075 2028 Harrison Street Suite 202 Hollywood, Florida 33020 Telephone: 954-414-8033 Facsimile: 954-924-1530 8 EFTA00185061

, Case 9:08-cv-80736-KAM D ument 362-42 Entered on FLSD iiket 02/10/2016 Page 10 of 10 CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the above and foregoing has been provided by United States mail and via facsimile to: ANN C. United States Attorney's Office, this 7th day of July, 2008. , AUSA, Brad Edwards, Esquire Attorney for Petitioner Florida Bar No. 542075 9 EFTA00185062

Case 9:08-cv-80736-KAM Document 362-43 Entered on FLSD Docket 02/10/2016 Page 1 of 3 EXHIBIT 113 EFTA00185063

Case 9:08-cv-80736-KAM Document 362-43 Entered on FLSD Docket 02/10/2016 Page 2 of 3 July 9, 2008 A. C. S Esq. Assistant United States Attorney United States Attorney's Office 500 South Australian Avenue 4th Floor. Suite 400 SENT VIA E-MAIL 8c FACSIMILE Re: Jeffrey E. Epstein Dear Ms. Villafana: 5,r‘Tas 40. sir 'JOSEPH R.ATTERBURY rt JACK A. GOLDBERGER JASON S.WEISS "Board Certified Criminal Trial Attorney T Member of Now Jersey di Florida Bart Thank you for your letter to me dated July 8, 2008 and the draft document dated, e-mailed and faxed to me at my office on June 30, 2008, styled "Notification of Identified Victims." I would like to address a few related issues. First, please note that we have several requests concerning any such notification. Specifically, we request that: (a) Any notification be sent to any individual by mail (or served upon their attorney, to the extent known), and we respectfully object to any service by hand, a method of service which carries the concomitant risk of conversations regarding the notification that potentially would place the federal authorities in a position of being advocates for civil litigation; (b) My notification be effectuated by a separate mailing to each individual without the inclusion of any language that appeared on the second page of your June 30, 2008 memorandum; i.e. rather than including in each notification a large section listing "identified individuate with redactions other than the name of the recipient (which we contend would be a clear and impermissible signal to any individual that the notification is a broad notification to numerous other alleged victims). Rather, a simple one page notification directed only to the recipient, and limited to the information currently on the first page of your draft memorandum would suffice. One Clearlake Centre, Suite 1400 250 Australian Avenue South West Palm Beach, FL. 33401 p wvvw.agwpacom 08-80736-CV-MARRA RFP WPB 00052 EFTA00185064

Case 9:08-cv-80736-KAM Document 362-43 Entered on FLSD Docket 02/10/2016 Page 3 of 3 (c) You eliminate from any notification any language that is currently contained in the "acknowledgment" section of the June 30, 2008 memorandum; and (d) You supplement the notification with the Government's previously made representation that it is not vouching for the veracity of any claim by any identified individual. See Letter from J. Sloman to E. (10/25/07). Second, please note also that we do not understand your request that Mr. Epstein and his attorneys execute the rider / acknowledgment contained within your June 30 hand-delivered draft. Speeifically,we do not believe that the Non-Prosecution Agreement requires Mr. Epstein's execution of any such additional stipulation. Because we want to ensure that Mr. Epstein continues to strictly comply with the letter of the parties' agreement, we respectfully ask that you explain why you believe that the Non-Prosecution Agreement requires execution of your stipulation. Our understanding of the Non-Prosecution Agreement is that it does not require Mr. Epstein to "acknowledge" anything not already contained within the four corners of the written ageement. The agreement certainly contains no written term obligating that he "waive any evidentiary challenge to the introduction of a copy" of any "Notification of Identified Victims" in "any judicial proceeding between any identified individual" and Mr. Epstein, as your memorandum currently requests. Further, please note that your June 30 stipulation, as drafted, is not limited to Section 2255 proceedings. Rather, yourJune 30 draft requires Mr. Epstein to waive evidentiary challenges in "any judicial proceeding" - - which clearly exceeds the bounds of the parties' written agreement. Third, I would respectfully request that you provide me with the names of the "pro bono lawyers" who, you indicated to me at our June 30 meeting at my office, were intending to represent certain persons identified on your June 30 draft notification, as well as any knowledge that the Government has as to how they were selected, and what communications the Government has had with them to date. Finally, please know that it is Mr. Epstein's firm intent to fulfill strictly each term and condition of his Non-Prosecution Agreement with the Government. Nothing hi this letter should be construed, however, as waiving any defense that may be available to Mr. Epstein under the parties' written agreement. I look forward to your response. Until then, I remain, V trul yours, Ja A. Goldberger cc: Jeffrey Epstein 08-80736-CV-MARRA RFP WPB 000525 EFTA00185065

Case 9:08-cv-80736-KAM Document 362-44 Entered on FLSD Docket 02/10/2016 Page 1 of 3 EXHIBIT 114 EFTA00185066

Case 9:08-cv-80736-KAM Document 362-44 Entered on FLSD Docket 02/10/2016 Page 2 of 3 U.S. Department of Justice United States Attorney Southern District of Florida 500 South Australian Ave.. Suite 400 West Palm Beach, FL 33401 Facshnile: July 9, 2008 VIA FACSIMILE Jack A. Goldberger, Esq. Atterbury, Goldberger & Weiss, P.A. One Clcarlake Centre, Suite 1400 250 Australian Ave S. West Palm Beach, FL 33401-5015 Re: Jeffrey Epstein Dear Mr. Goldberger: Thank you for your letter of today's date regarding the proposed Victim Notification. Let me address some of the items in your letter. We have no objection to doing individual mailings. The Notification was drafted in that way in order to minimize the number of documents that Mr. Epstein would sign. Now that you have raised an objection to signing the Acknowledgment, each notification will list only the victim who is being notified. In light of Mr. Epstein's refusal to sign the Acknowledgment, the Acknowledgment portion has been deleted and the notification has been slightly modified in order to provide more complete information and it has been formatted as a letter rather than a more formal "Notification" document. We will not be including any statement that the U.S. Attorney's Office is not vouching for the veracity of any claim. As you know, the U.S. Attorney's modification of the 2255 portion of the Agreement now limits our victim list to those persons whom the United States 08-80736-CV-MARRA RFP WPB 000526 EFTA00185067

Case 9:08-cv-80736-KAM Document 362-44 Entered on FLSD Docket 02/10/2016 Page 3 of 3 JACK GOLDBERGER, ESQ. JULY 9, 2008 PAGE 2 was prepared to include in an indictment. This means that, pursuant to Justice Department policy, these are individuals for whom the United States believes it has proof beyond a reasonable doubt that each of them was a victim of an enumerated offense. There will be no statement one way or the other regarding the validity of any claim. You have asked for an explanation of why I believe the Acknowledgment portion is required by the lens of the Agreement. Under a strict reading of the Agreement, it is not required, other than to Acknowledge that the United States has performed its obligation of providing Mr. Epstein with a list of identified victims following his guilty plea and sentencing. The purpose of the Acknowledgment was to create one single document incorporating the parties' agreement on the single topic of the right to proceed under 18 U.S.C. § 2255. This would avoid litigation regarding the victims' rights to have access to the original Non-Prosecution Agreement. Without such an express Acknowledgment by Mr. Epstein that the Notice contains the substance of that Agreement, I believe that the victims will have a justification to petition for the entire agreement, which is contrary to the confidentiality clause that the parties have signed. If you believe that particular words are objectionable, I am happy to consider a modification. As I mentioned to you last week, I will provide you with the names of the attorneys currently representing the victims when we have compiled all of that in fonnation. Some of the victims are represented by attorneys from the South Carolina Victim Assistance Network and the Maryland Crime Victims Resource Center, both of which were recommended by a victims' rights organization that receives grants from the Justice Department. If you have any suggestions for a modification of the Acknowledgment, please let me know. Sincerely, United States Attorney cc: Karen Atkinson, AUSA By: Assistant United States Attorney 08-80736-CV-MARRA RIP WPB 000527 EFTA00185068

Case 9:08-cv-80736-KAM Document 362-45 Entered on FLSD Docket 02/10/2016 Page 1 of 4 EXHIBIT 115 EFTA00185069

Case 9:08-cv-80736-KAM Document 362-45 Entered on FLSD Docket 02/10/2016 Page 2 of 4 U.S. Department of Justice FILE COPY United Stales A►torney Southern District of Florida 500 South Australian Ave., Suite 400 IVest Palm Beach, FL 33401 July 9, 2008 NOTIFICATION OF IDENTIFIED VICTIM NOTICE: IN ACCORDANCE WITH TITLE 18, UNITED STATES CODE, SECTION 3509(d) AND FLORIDA LAW, THE ATTACHED DOCUMENT IS TO BE TREATED AS CONFIDENTIAL AND SHALL NOT BE DISCLOSED EXCEPT IN CONNECTION WITH A LEGAL PROCEEDING. 08-80736-CIV-MARRA 000777 EFTA00185070

of Florida asks that you provide the following notice to your client, Case 9:08-c -80736-KAM Document 362-45 Entered on FLSD Docket 02/10/2016 Page 3 of 4 U.S. Department of Justice "•• United States Attorney Southern District of Florida F P' 500 South Australian Ave., Suite 400 West Palm Beach, FL 3340! Facsimile: July 9, 2008 VIA FACSIMILE Brad Edwards, Esq. The Law Offices of Brad Edwards & Associates, LLC 2028 Harrison Street, Suite 202 Hollywood, Florida 33020. Re: Jeffrey Epstein/ NOTIFICATION OF IDENTIFIED VI A Dear Mr. Edwards: By virtue of this letter, the United States Attorney's Office for the Southern District II On June 30, 2008, Jeffrey Epstein (hereinafter referred to as "Epstein) entered a plea of guilty to violations of Florida Statutes Sections 796.07 (felony solicitation of prostitution) and 796.03 (procurement of minors to engage in prostitution), in the 15th Judicial Circuit in and for Palm Beach County (Case Nos. 2006-cf-009454AXXXMB and 2008-cf- 009381AXXXMB) and was sentenced to a term of twelve months' imprisonment to be followed by an additional six months' imprisonment, followed by twelve months of Community Control 1, with conditions of community confinement imposed by the Court. In light of the entry of the guilty plea and sentence, the United States has agreed to defer federal prosecution in favor of this state plea and sentence, subject to certain conditions. One such condition to which Epstein has agreed is the following: "Any person, who while a minor, was a victim of a violation of an offense enumerated in Title 18, United States Code, Section 2255, will have the same rights to proceed under Section 2255 as she would have had, if Mr. Epstein 08-80736-CI V-MARRA 000778 EFTA00185071

Case 9:08-cv-80736-KAM Document 362-45 Entered on FLSD Docket 02/10/2016 Page 4 of 4 BRAD EDWARDS, ESQ. NOTIFICATION OF IDENTIFIED VICTIM JULY 9, 2008 PAGE 2 OF 2 had been tried federally and convicted of an enumerated offense. For purposes of implementing this paragraph, the United States shall provide Mr. Epstein's attorneys with a list of individuals whom it was prepared to name in an Indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining which evidentiary burdens if any a plaintiff must meet, shall consider that it is the intent of the parties to place these identified victims in the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less." Through this letter, this Office hereby provides Notice that your client, _J is an individual whom the United States was prepared to name as a victim of an enumerated offense. Should your client decide to file a claim against Jeffrey Epstein, his attorney, Jack Goldberger, asks that you contact him at Atterbury Goldberger and Weiss, 250 Australian Avenue South, Suite 1400, West Palm Beach, FL 3340!, Please understand that neither the U.S. Attorney's Office nor the Federal Bureau of Investigation can take part in or otherwise assist in civil litigation; however, if you do file a claim under 18 U.S.C. § 2255 and Mr. Epstein denies that your client is a victim of an enumerated offense, please provide notice of that denial to the undersigned. Please thank your client for all of her assistance during the course of this examination and express the heartfelt regards of myself and Special Agents and for the health and well-being of Ms. cc: Jack Goldberger, Esq. UNITED STATES ATTORNEY By: A ASSISTANT U.S. ATTORNEY 08-80736-C1V-MARRA 000779 EFTA00185072

Case 9:08-cv-80736-KAM Document 362-46 Entered on FLSD Docket 02/10/2016 Page 1 of 4 EXHIBIT 116 EFTA00185073

Case 9:08-cv-80736-KAM Document 362-46 Entered on FLSD Docket 02/10/2016 Page 2 of 4 U.S. Department of Justice United Stales Attorney Southern District of Florida 500 South Australian Ave., Suite 400 West Palm Beach, FL 3340! July 9, 2008 NOTIFICATION OF IDENTIFIED VICTIM NOTICE: IN ACCORDANCE WITH TITLE 18, UNITED STATES CODE, SECTION 3509(d) AND FLORIDA LAW, THE ATTACHED DOCUMENT IS TO BE TREATED AS CONFIDENTIAL AND SHALL NOT BE DISCLOSED EXCEPT IN CONNECTION WITH A LEG AL PROCEEDING. 08-80736-CIV-MARRA 000774 EFTA00185074

Case 9:08- :0736-KAM Document 362-46 Entered on FLSD Docket 02/10/2016 Page 3 of 4 U.S. Department of Justice United States Attorney Southern District of Florida 500 South Australian Ave., Suite 4UU West Palm Beach. FL 33401 July 9, 2008 VIA FACSIMILE Brad Edwards, Esq. The Law Offices of Brad Edwards & Associates, LLC 2028 Harrison Street, Suite 202 Hollywood, Florida 33020. Re: Jeffrey Epsteins eurr aNOTIFICATION OF IDENTIFIED VI Dear Mr. Edwards: By virtue of this letter, the United States Attorney's Office for the Southern District of Florida asks that you provide the following notice to your client, On June 30, 2008, Jeffrey Epstein (hereinafter referred to as "Epstein) entered a plea of guilty to violations of Florida Statutes Sections 796.07 (felony solicitation of prostitution) and 796.03 (procurement of minors to engage in prostitution), in the I 5th Judicial Circuit in and for Palm Beach County (Case Nos. 2006-cl-009454AXXXMI3 and 2008-cf- 009381AXXXMB) and was sentenced to a term of twelve months' imprisonment to he followed by an additional six months' imprisonment, followed by twelve months of Community Control 1, with conditions of community confinement imposed by the Court. In light of the entry of the guilty plea and sentence, the United States has agreed to defer federal prosecution in favor of this state plea and sentence, subject to certain conditions. One such condition to which Epstein has agreed is the following: "Any person, who while a minor, was a victim of a violation of an offense enumerated in Title 18, United States Code, Section 2255, will have the same rights to proceed under Section 2255 as she would have had. if Mr. Epstein 08-80736-CIV-MARRA 000775 EFTA00185075

Case 9:08-cv-80736-KAM Document 362-46 Entered on FLSD Docket 02/10/2016 Page 4 of 4 BRAD EDWARDS, ESQ. NOTIFICATION OF IDENI IVIED VICTIM JULY 9, 2008 PAGE 2 OF 2 had been tried federally and convicted of an enumerated offense. For purposes of implementing this paragraph, the United States shall provide Mr. Epstein's attorneys with a list of individuals whom it was prepared to name in an Indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority interpreting this provision, including any authority determining which evidentiary burdens if any a plaintiff must meet, shall consider that it is the intent of the parties to place these identified victims in the same position as they would have been had Mr. Epstein been convicted at trial. No more; no less." Through this letter, this Office hereby provides Notice that your client, El_- IM is an individual whom the United States was prepared to name as a victim of an ted offense. Should your client decide to file a claim against Jeffrey Epstein, his attorney, Jack Goldberger, asks that you contact him at Atterbury Goldber er and Weiss, 250 Australian Avenue South, Suite 1400, West Palm Beach, FL 33401, Please understand that neither the U.S. Attorney's Office nor the Federal Bureau of Investigation can take part in or otherwise assist in civil litigation; however, if you do file a claim under 18 U.S.C. § 2255 and Mr. Epstein denies that your client is a victim of an enumerated offense, please provide notice of that denial to the undersigned. Please thank your client for all other assistance during the course of this examination and express the heartfelt regards of m self and Special Agents and for the health and well-being of Ms.• cc: Jack Goldberger, list'. By: UNITED STATES ATTORNEY A. ASSISTANT U.S. ATTORNEY 08-80736-CIV-MARRA 000776 EFTA00185076

Case 9:08-cv-80736-KAM Document 362-47 Entered on FLSD Docket 02/10/2016 Page 1 of 4 EXHIBIT 117 EFTA00185077

Case 9:08-cv-80736-KAM Document 362-47 Entered on FLSD Docket 02/10/2016 Page 2 of 4 U.S. Department of Justice United States Attorney Southern District of Florida Ant Yitlajiina Wa rr i Facsimile FACSIMILE COVER SHEET TO: Jack Alan Goldberger DATE: July 10.2008 FAX NO. PHONE NO. # OF PAGES: 2 RE: Jeffrey Epstein FROM: A. PHONE NO. VILLAFA1CIA, Assistant U.S. Attorney COMMENTS: 08-80736-CV-MARRA RFP WPB 000535 EFTA00185078

Case 9:08-cv-80736-I<AM Document 362-47 Entered on FLSD Docket 02/10/2016 Page 3 of 4 JOSEPH R.ATTERBURY 11 JACK A. GOLDBERGER JASON S.WEISS ROAN CeetIlled CrenbulTrIal Attorney Member of New Jersey a Florida Bus July 10, 2008 A. up C. pm Esq. Assistant Un e u es Attorney 500 S. Australian Avenue - & FACSIMILE Re: Jeffrey E. Epstein Dear Ms. Thank you for your letter of yesterday. Kindly allow me a few follow-up points. First, we respectfully request a reasonable opportunity to review and comment on a draft of the modified notification letter you Intend to mail before you send it. Second, we respectfully ask that you provide us with the identity of the victims' rights organization described in your letter; the name and contact information of the person at that organization with whom the Government has been communicating; copies of any communications with that organization and the pro-bono lawyers/groups who were recommended by that organization; and a description of any non-written communications that the Government has had with that organization and the pro-bono lawyers/groups. Third, while we appreciate your offer to disclose the names of the lawyers currently representing the individuals when you have finished compiling all of that Information, we would be very grateful if you would provide any contact information you do have, on a rolling basis. Fourth, would it be possible for you to advise us of the full name of the minor to whom you have referred by initials, as well as the identities of the three Individuals whom the Government notified about the deferred-prosecution agreement shortly after its signing (as One Clearlake Centre, Suite 1400 250 Australian Avenue South West Palm Beach. FL 33401 p ei300 f www.agwpa.com 08-80736-CV-MARRA RFP WPB 000536 EFTA00185079

Case 9:08-cv-80736-KAM Document 362-47 Entered on FLSD Docket 02/10/2016 Page 4 of 4 indicated In your letter of December 13, 2007)7 Fifth, please recall that Mr. Illwrote to Judge on October 25, 2007 that "The United States takes no position as o the validity of any such claim under this statute." To avoid any appearance that the United States is endorsing or encouraging litigation by the identified individuals, we believe that such a statement should be included in any notification letter. I look fonyard to receiving your Input on these Issues. Until then, I remain, Jack A. Goldberger JAG/na co; Jeffrey E. Epstein 08-80736-CV-MARRA REP WPB 000537 EFTA00185080

Case 9:08-cv-80736-KAM Document 362-48 Entered on FLSD Docket 02/10/2016 Page 1 of 2 EXHIBIT 118 EFTA00185081